Privacy Policy

Date of Last Revision: 24 May 2018

This Privacy Policy governs the process (obtaining, recording, holding, disclosing etc.) that Vinchain.io
(hereinafter “Vinchain”, “we”, “us”, “our”), follows in dealing
with Personal Information collected from users (hereinafter "users", "you", "your"
or "yours") of the https://vinchain.io website (hereinafter "Website"). It also governs the
services we offer or any other features, technologies or functionalities provided by Vinchain on the website or
through any of our mobile applications. Any online services offered by Vinchain that link to or reference this
Privacy Policy are subject to its terms of use. By using the Website as well as Services, you signal your
acknowledgment to this Privacy Policy. In the event that you do not consent to this Privacy Policy, kindly do
not use our Website. Your continued use of the Website following the posting of changes to this policy will be
deemed as your acceptance of those changes.

The security of your Personal Information is essential to us. VinChain has safeguards set up to ensure the
security of your Personal Information with us. This policy describes how we may collect, use, disclose, process
and manage Personal Information.

Our Website may contain links to other websites which are not maintained by VinChain. This Privacy Policy only
applies to Personal Information gathered by us through our websites as well as Services and does not have any
significant bearing on third party websites and services that you may access through these links. When visiting
these third-party websites, you should read their privacy policies, which will apply to your use of these
websites.

PERSONAL INFORMATION WE COLLECT

Section 326 of the USA PATRIOT ACT requires all financial institutions to obtain, verify, and
record Personal Information that identifies each person who opens an account. This federal requirement applies
to all new customers. This Personal Information is used to assist the United States government in the fight
against the funding of terrorism and money-laundering activities. What this means for you: when you open an
account, we ask you for your name, address, date of birth, and other identifying Personal Information.

In addition, we are a global company and thus may conduct business and collect Personal
Information from individuals and institutions located within the European Economic Area (“EEA”). We
are required to protect Personal Information processed in the EEA in accordance with the General Data Protection
Regulation (“GDPR”). To understand more about how we protect the data we collect from individuals
and institutions located within the EEA, please see the “Privacy Statement for Data Subjects Whose
Personal Information May Be Collected in or from the EEA” section below.

Personal Information we collect may include the following:

Individual Customer - We attempt to collect, verify, and authenticate the following:

Additional Personal Information or documentation at the discretion of our Compliance Team.

Institutional Customer - We attempt to collect, verify, and authenticate the following:

Institution legal name;

Employer Identification Number (“EIN”) or any comparable identification number issued by a
government;

Full legal name (of all account signatories and beneficial owners);

Email address (of all account signatories);

Mobile phone number (of all account signatories);

Address (principal place of business and/or other physical location);

Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation,
unexpired government-issued business license, trust instrument, or other comparable legal documents as
applicable);

Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual
beneficial owner that owns 10% or more of the institutional customer entity, as well as all account
signatories; and

Personal Information for each entity beneficial owner that owns 10% or more of the institutional customer
entity (see the “Individual Customer” section above for details on what Personal Information
we collect for individuals).

You will be allowed to access, review, correct, and ensure the accuracy of the Personal Information you
have provided from time to time. We will also do our part to ensure the accuracy of your Personal
Information.

Personal Information you provide during the registration process may be retained, even if your
registration is left incomplete or abandoned. If you are located within the EEA, your Personal
Information will not be retained without your consent.

HOW WE USE AND SHARE PERSONAL INFORMATION WE COLLECT

We may use Personal Information that we collect on an aggregate or de-identified basis for various business
purposes, where permissible under the applicable laws and regulations.

We will ask the User’s separate consent before using the collected Personal Information for purposes that
are not listed herein.

We store the collected Personal Information for as long as it is necessary to provide Services to you. We for the
most part store Personal Information on your transactions for five years. Personal Information associated with
your account will be kept until the point when your record is erased unless we no longer need the data to
provide Services.

Disclosing Your Personal Information

We will not sell or trade your Personal Information unless we provide you with advance notice. We may share
Personal Information about you as follows:

With current and future VinChain partners, affiliates, subsidiaries, and other companies under common
control and ownership in the course of delivering our Services to you;

With affiliates, consultants, and other service providers when we trust it will improve the Services and
products we can give to you, or for legal and routine business reasons, so long as those parties agree
to keep this information confidential

We may also release information when its release is appropriate to comply with the law, enforce our
Website policies, or protect our or others' rights, property or safety. This does not include
website hosting partners and other parties who assist us in operating our

Website, conducting our business, or serving our users;

With your consent or at your direction.

We may also share aggregated or de-identified Personal Information, which cannot reasonably be used to
identify you.

CHILDREN UNDER THE AGE OF 18

VinChain Services are not intended or directed at individuals under the age of 18. Therefore, individuals under
the age of 18 may not create an account or otherwise access or use the Services.

ACCESS, CORRECTION, AND DELETION OF PERSONAL INFORMATION

You have the right to ascertain whether we hold your accurate and current Personal Information, to obtain a copy
of your Personal Information that you submitted as permitted by law, and to correct any of your data that is
inaccurate. You may also request that we inform you of the type of Personal Information we hold with regard to
you, subject to restrictions on our providing copies of certain data pursuant to our obligations under BSA and
AML regulations and/or data provided to our legal counsel in defense of a claim against us. You may also request
that we delete your Personal Information, subject to the restrictions on data deletion pursuant to relevant data
retention and destruction restrictions under applicable laws and regulations, such as those related to the BSA
and AML. For data access, correction, or deletion requests, please contact info@vinchain.io.

When handling a data access, correction, or deletion request, we check the identity of the requesting party to
ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond
to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to
charge you a reasonable fee for compliance with your request.

DIRECT MARKETING

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting
services, products, facilities, or activities to you using information collected from you. We will provide you
with an opportunity to opt-in to such communications and will only send them to you if you consent.

We will not provide your Personal Information to third parties for direct marketing or other unrelated purposes
without your written consent.

CHANGES TO THE PRIVATE POLICY

We may revise this arrangement every once in a while to guarantee that this policy is reliable with any
improvements to the way VinChain uses your Personal Information. IT can also be amended to be aligned with any
progressions to the laws and controls pertinent to VinChain. In the event that we do, we will let you know by
appropriate means, such as by posting the revised policy on our Website with a new “Last Updated”
date. All changes will become effective when posted unless indicated otherwise.

CONTACT US

We provide you with access to your Personal Information. You may update or delete Personal Information at any
time at your own discretion. We won't keep outdated or deleted Personal Information unless we have to do so
for legitimate business purposes or in accordance with legislative or regulatory requirements.

WHAT ARE COOKIES

As is normal practice with every single professional website, this site uses cookies, which are which are tiny
files that are downloaded to your computer to enhance your experience. This page depicts what information they
accumulate, how we use it and why we sometimes need to store these cookies. We will likewise share how you can
keep these cookies from being stored however this may downgrade or 'break' certain components of the
site's functionality. For more general information on cookies see the Wikipedia article on HTTP
Cookies...

COOKIES

When you access VINchain, we may make use of the standard practice of placing tiny data files called cookies,
flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other
devices used to visit VINchain.We use Cookies to help us recognize you as a customer, collect information about
your use of VINchain to better customize our services and content for you, and collect information about your
computer or other access devices to (i) ensure compliance with our Bank Secrecy Act (“BSA”) and
anti-money laundering (“AML”) program (“BSA/AML Program”) and (ii) ensure that your
account security has not been compromised by detecting irregular or suspicious account activities.When you log
on to the VINchain website, you will be provided with the option to accept or reject cookies. Please note that
if you reject cookies, you will not be able to use some or all of VINchain. If you do not consent to the placing
of Cookies on your device, please do not visit, access, or use VINchain.

EMAILS

Email that you provide for us will be used for notifying about product development updates only.

PRIVACY STATEMENT FOR DATA SUBJECTS WHOSE PERSONAL INFORMATION MAY BE COLLECTED IN OR FROM THE EEA

While customers who are located in the EEA are customers of our US entity, we recognize and, to the extent
applicable to us, adhere to relevant EEA data protection laws.

COLLECTION AND TRANSFER OF DATA OUTSIDE THE EEA

As outlined above, we may collect Personal Information from Data Subjects located in the EEA. To facilitate the
services we provide to customers located in the EEA, we request explicit consent for the transfer of Personal
Information from the EEA to the US. If you are an individual located in the EEA and you decline to consent to
such transfer, you will no longer be able to use VINchain and our services. You will have the ability to
withdraw Digital Assets and fiat currency; however, all other functionality will be disabled.

LAWFUL GROUNDS TO PROCESS AND OBTAIN CONSENT

We process the Personal Information of Data Subjects who are located in the EEA for one or more of several lawful
purposes, including:

With your explicit consent:

To provide you with VINchain and our services, including customer service support;

To optimize and enhance VINchain for all customers or for you specifically;

To comply with legal obligations:

To conduct anti-fraud and identity verification and authentication checks (you authorize us to
share your Personal Information with our third-party service providers, who may also conduct
their own searches of publicly available Personal Information about you);

Data Subjects in the EEA may withdraw consent at any time where consent is the lawful basis for processing their
Personal Information. Should a Data Subject withdraw consent for processing or otherwise object to processing
that impedes our ability to comply with applicable laws and regulations, a Data Subject may be unable to avail
him or herself of the services we provide.

AUTOMATED DECISION-MAKING

We do not engage in automated decision-making.

NON-DISCLOSURE OF PERSONAL INFORMATION

Our employees are prohibited, either during or after their employment, from disclosing Personal Information to
any person or entity outside of our company, including family members, except under the circumstances described
above. An employee is only permitted to disclose the Personal Information of a customer to such other employees
who need access to such information in order to deliver our services to that customer.

OUR CONTACT INFORMATION FOR PERSONS LOCATED WITHIN THE EEA

If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your
Personal Information, you may contact us at: info@vinchain.io.

If, as an EEA Citizen, you believe that we have not adequately resolved any such issues, you have the right
contact the EU supervisory authority.

MORE INFORMATION

Hopefully, that has clarified things for you and as was previously mentioned if there is something that you aren't
sure whether you need or not, it's usually safer to leave cookies enabled in case it does interact with one
of the features you use on our site. However, if you are still looking for more information, then you can
contact us through one of our preferred contact methods.

If any of your information that we hold is incorrect, you can change it by contacting us at info@vinchain.io

With any other questions or concerns about this Privacy Policy, you are encouraged to contact us at
info@vinchain.io

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